Must a copy of the homeownership counseling notice be kept in the customers file? I don't see anything that says a bank must keep a copy. Our procedures detailed how we review the report, do our mailings etc but until 2013 we did not keep a copy of the letter. (Began as a best practice) OCC is asking to see notices sent from 2012 and we don't have them. I will explain our process to them (pre and post saving) but wanted to make sure I didn't miss somewherethat it was required to keep a copy. Thanks.

BTW - I'm talking the form 92070 SCRA notice not the HUD counseling notice

There is no regulatory retention requirement - procedures should be enough.